1. Research Reactor Decommissioning Demonstration Project (R2D2)
Release of Buildings and Sites/Final Survey
Humboldt Bay, Eureka, California
28 September - 2 October 2015
10. IAEA Recommendations on the Release of Materials / Buildings and Sites
Vladan Ljubenov
Division of Radiation, Transport and Waste Safety
Waste and Environmental Safety Section

2. Content Context Terminology
The process for release of sites from regulatory control - general
Protection and safety aspects
Definition of release criteria
Responsibilities
Details of the process - site characterization, cleanup actions, release of materials (clearance), release of buildings, final survey
Unrestricted / restricted use after release
Summary
References

3. Context We are still in decommissioning !!!
Dismantling and decontamination activities for the SSCs are completed and the associated waste is removed.
We are dealing with the site of the former facility, on which some remaining building structures may exist.
The objective is to release the site from regulatory control (to complete the decommissioning process).
Release of sites is an authorised activity !!!
The site and the remaining building structures may be contaminated, so they may require a cleanup actions to be performed to meet the site release criteria.
This presentation does not cover situations after an accident.
During cleanup and release of sites, release of materials from regulatory control (clearance) may occur. Clearance is not addressed in details in this presentation.

4. Terminology
At the end of the operational phase (prior to decommissioning) we deal with a facility. It includes all the SSCs, the associated land, buildings and equipment in which radioactive material is used, processed, handled or stored.
During decommissioning the SSCs of the facility are gradually dismantled and removed.
Towards the end of the decommissioning there is no facility anymore. We now deal with a site – in the context of release of sites it is defined as land together with any buildings or other remaining structures being considered for release from regulatory control.
In order to meet the criteria for site release, a cleanup may be needed - any measures that may be carried out to reduce the radiation exposure from existing contamination through actions applied to the contamination itself (the source) or to the exposure pathways to humans and to the environment.

5. Terminology
Cleanup plan – a document prepared by the operator which describes cleanup actions and protective measures to be implemented. Usually is part of the overall decommissioning plan.
Release from regulatory control – general term, used for both material/waste and sites
Clearance – specific term used for release of material/waste from regulatory control
Waste – not needed, no intention for reuse/recycle, has to be disposed off, could be non-radioactive or radioactive waste
Material – intended for reuse/recycle
Clearance is different than discharge - planned and controlled release of (usually gaseous or liquid) radioactive material to the environment during normal operation of a facility, within limits authorized by the regulatory body, generally with the purpose of dilution and dispersion

6. WS-G-5.1 published in 2006

7. The Process for the Release of Sites from Regulatory Control
Identification of the site release criteria (generic or site specific)
Site characterization
Comparison of the site characterization results with the site release criteria
If the site does not meet the release criteria, cleanup actions will be needed
Evaluation of the cleanup options, selection of an optimal cleanup option and end-point
Development of a Cleanup Plan by the operator (preferably as part of the overall decommissioning plan, should define restrictions, if any)
Review/approval by the regulatory body
Implementation of the cleanup actions
Final radiological survey to demonstrate compliance with the site release criteria for restricted or unrestricted release
Preparation of the Final Radiological Survey Report and submission to the RB
Review of the Final Radiological Survey Report by the RB
Independent confirmatory survey by the RB (optional)
Decision by the regulator on release of site (with or without restrictions)
Implementation of restrictions, institutional control and monitoring (if any), record keeping

8. This process should be part of the decommissioning process, and should be done under the decommissioning authorization (licence).

9. Protection and Safety Aspects
The release of sites from regulatory control is the final stage of the decommissioning process – falls under the planned exposure situation.
Requirements of the GSR Part 6 (decommissioning) and the GSR Part 3 (BSS) for planned exposure situations are applicable to cleanup and release of sites.
All the other requirements referenced in these publications are applicable as well.

10. Protection and Safety Aspects
Objective - to ensure proper protection of workers, the public and the environment during the cleanup and after the release of the site.
The principles of justification, dose limitation and optimization of protection are applicable to cleanup and release of sites.
Dose limit of 1 mSv in a year for a member of the public is an upper bound for the sum of all exposures arising from authorized activities.
Optimization of protection should include:
evaluation of the exposure of workers during cleanup activities (i.e. including material characterization and radioactive waste management);
evaluation of long term exposure of the public arising from the residual site contamination after site release.
This evaluation need to ensure that the protection of workers and the public is optimized below the dose constraints defined by the RB.

11. Protection and Safety Aspects
This dose constraint should take into account multiple pathways of exposure and should not exceed 300 μSv in a year above background.
Prospective effective doses to members of the public above the background levels (before the commissioning of the facility) that would be received after the site has been released;
Summed effective doses arising from the site (considered as one source), including land and buildings and other structures;
The uncertainties associated with knowledge of the site and its potential uses after its release should be taken into account in the estimation of prospective doses.
The applicable dose constraint for the public after the release of a site should be expected to be no higher than that applied for the operational phase of the facility lifetime.

12. Protection and Safety Aspects
The site dose release criteria should be based on an optimization of protection below that dose constraint, with account taken of the fact that optimization below the order of 10 μSv in a year might not be warranted on radiological protection grounds.
For the unrestricted use of a site, it should be ensured by means of the optimization of protection that the effective dose to a member of a critical group is kept below the dose constraint of 300 μSv in a year.
For the restricted use of a site it should be ensured that, with restrictions in place, the effective dose should not exceed the dose constraint of 300 μSv in a year and that if the restrictions were to fail in the future the effective dose should not exceed 1 mSv in a year.
Note the difference from the criteria for release of materials !!! (see Workshop #9, Karlsruhe 2010)
It is reasonable and appropriate to have different dose constraints for the release of sites than for the clearance of material from regulatory control.

13. Protection and Safety Aspects
Clearance of material may take place frequently during operation and decommissioning of a facility, as well as at the termination stage.
The cleared material may enter into trade with a broad range of potential uses and therefore should comply with clearance criteria, which are of the order of 10 μSv in a year.
The dose criteria for the release of land from regulatory control should be optimized and can be higher than those for the clearance of material.
Land remains in place, higher degree of certainty about the potential uses of the land after its release from regulatory control
No possibility to simultaneous exposure to more than one site
It is reasonable to allow a larger fraction of the individual dose limit for the release of sites (i.e. less than 300 μSv in a year) than for the clearance of material (of the order of 10 μSv or less in a year).
Some countries apply a 10 µSv/y concept also for the release of sites.

14. Dose limit (1mSv in a year) Dose constraint (300 Sv in a year)
Radiological Approach to the Release of Sites from Nuclear Regulatory Control (WS-G-5.1)
Dose limit (1mSv in a year)
Region for release of a site for restricted use if restrictions fail
Dose constraint (300 Sv in a year)
Region of optimization for site release for restricted use provided that restrictions are in place
Region of optimization for unrestricted site use
Optimised site dose release criteria
Region where dose reduction measures are unlikely to be warranted / release of materials from regulatory control
10  Sv in a year

15. Protection and Safety Aspects
As part of the decision making process for the release for unrestricted use of land and associated buildings or structures, consideration should be given to the potential circulation of material arising from any future modification of the buildings, including demolition after release of the site.
Material originating from a released site needs to comply with the national requirements for radiation protection for material outside the scope of regulatory control.
The assessment of material originating from the site should be an integral part of the optimization analysis for the cleanup process.
Scenarios giving rise to exposure from sites released for unrestricted use should be realistic and should consider the potential uses of the material from the released site.

16. Definition of Release Criteria
The release criteria are defined on the basis of the evaluation of potential radiological consequences associated with the site after its release.
All relevant exposure pathways should be considered. The dose assessment should include direct radiation, inhalation and ingestion pathways to derive release criteria.
Two main approaches can be taken
The RB may develop generic release criteria;
The operator can derive site specific release criteria, on the basis of the optimization process, which the RB should then approve.
The first approach may result in conservative release criteria because of the generic assumptions in the dose assessment. This could lead to cleanup activities being more extensive and costly than necessary.
The second approach places an additional burden on the operator and the RB, but it is likely to result in a less stringent set of release criteria for the site.

17. Definition of Release Criteria
An optimization process should be used to develop release criteria.
In accordance with the guidance of the regulatory body, the operator should determine which scenarios and which corresponding exposure pathways are most applicable for the site.
Involvement of interested parties is important in the selection of the scenarios to be evaluated (e.g. in identifying the potential activities at the site after release).
The selected scenarios and pathways should be used as the basis for dose assessments to develop release criteria for the site.
The release criteria are derived from an iterative analysis of a set of all reasonable scenarios, with account taken of the uncertainties in relation to the characteristics of the site and its potential use.

18. Definition of Release Criteria
The following activities should be performed on the basis of optimization of the overall decommissioning actions, the end state of the site as defined in the decommissioning plan, the associated dose criteria, the dose constraints and the site description:
Definition of the scenarios and identification of the exposure pathways;
Compilation of the specific data and information for the scenarios and pathways;
Definition of the conceptual models for the site;
Conduct of dose assessments;
Determination of the release criteria.
The release criteria should be expressed in measurable and verifiable units (Bq/g or Bq/cm2).
The IAEA does not provide radionuclide specific site release levels (as it does for the release of materials)

19. Definition of Release Criteria
The release criteria should take into account the background radiation levels existing on the site prior to the operation of the facility, as well as the baseline concentrations of natural radionuclides in the construction materials (concrete, metals, or any other respective material).
Before commissioning a new facility, the operator should ensure that a baseline radiological survey of the site is performed to define the levels of background radiation at the facility site.
For existing facilities for which no such baseline survey was carried out in the past to determine these background levels, data from analogous, undisturbed areas with similar characteristics should be used.
Uncertainties should be taken into account in determining the impact of the release of the site, in optimizing the protection and in defining the release criteria:
Uncertainties related to the level of contamination, hidden buried structures and waste, uncertainties associated with the future use of the remaining buildings on the released site

20. Responsibilities - Government
Formulate a policy for the release of sites, including cleanup;
Ensure that an adequate legal and regulatory framework, supported where necessary by appropriate guidance, is in place so that workers, the public and the environment are protected during cleanup and after the release of sites from regulatory control;
Specify the responsibilities of the parties involved;
The legal and regulatory framework should ensure:
provision for the termination of a practice and release of a site for (un)restricted use;
basis for establishing any restrictions that may be placed upon the site use/access;
time frames for institutional control;
availability of adequate funding mechanisms and definition of responsibilities for financing of cleanup, including maintaining restrictions;
Information/record management in accordance with the records retention requirements (particularly important where restrictions are imposed on the future use of sites);
provision for the RB to review and approve the proposed cleanup actions (as part of a decommissioning plan).

21. Responsibilities – Regulatory Body
Establish safety requirements and guidelines for the planning, approval and conduct of cleanup actions, for the management of contaminated material and the waste that arises from this process, and for the release of land, buildings and structures from regulatory control;
Establish, promote and adopt criteria and guidance for the cleanup and release of sites as a part of decommissioning;
Review and approve submissions from operators for cleanup and release of the site from regulatory control as part of the decommissioning plan (including the proposed cleanup actions and release criteria for the site);
Develop criteria and methods for assessing the adequacy of the implementation of cleanup;
Issue, amend, suspend or revoke authorization for decommissioning, including provision for cleanup and release of sites from regulatory control;
Perform regulatory inspections (e.g. independent measurements) to verify that safety requirements and conditions for authorization have been met and that the site meets the approved release criteria after cleanup;

22. Responsibilities – Regulatory Body
Review of final radiological survey documentation;
Take appropriate actions whenever safety requirements and conditions for authorization are not met;
Evaluate and approve revised cleanup actions and/or institutional control measures if compliance with the release criteria is not achieved;
Evaluate reports on unplanned occurrences and events;
Coordinate the regulatory process of cleanup and release of sites with other regulatory bodies responsible for other issues such as nonradiological hazards and transport;
Cooperate with other relevant authorities and interact with interested parties, providing them with the necessary information on safety matters associated with the cleanup and release of the site;
If the operator is unable to fulfil its responsibilities to ensure release of the site in compliance with established regulatory criteria, the RB should exercise its authority to select a competent organization to finalize the cleanup using the financial arrangements provided by the operator or an authorized party;

23. Responsibilities – Regulatory Body
If no funds or insufficient funds are available for completion of the cleanup of the site for unrestricted use, the RB should approve the measures for restricted use and should define procedures and responsibilities for the cleanup of the site, the maintenance of restrictions, the suspension of authorization and the release of the site;
Ensure that relevant documents and records are prepared by the operator, kept for an agreed time and maintained to a specified quality by appropriate parties before, during and after decommissioning;
In the event that the operator ceases its activities or ceases to exist, the RB should take or assign the responsibility for keeping records about the site;
Ensure that an effective record management system for the released sites is in place and is maintained for future users of the sites.

24. Responsibilities – Operator (Licensee)
Overall responsibility for safety (including the cleanup of the site);
Although the performance of specific tasks may be delegated to a subcontractor, the ultimate responsibility for safety remains with the operator.
Preparing and submitting to the regulatory body details of the cleanup actions and protective measures to be taken during and after the cleanup of the site. These documents will normally be part of the decommissioning plan and the supporting documentation;
WS-G-5.1 provides an example of the content of a cleanup plan.
Ensuring the availability of the resources (including financial resources), expertise/knowledge necessary for the cleanup and release of the site;
Performing the required cleanup actions, after their approval by the regulatory body, and demonstrating that the release criteria for the site have been met;
Management of all the cleanup actions, including management of the radioactive waste generated during cleanup in a way compliant with the relevant safety requirements and criteria.

25. Site Characterization
Objective – to assess radiological conditions on the site and the need for a cleanup prior to the site release and to provide an input for definition of the site release criteria.
Media for characterization – soil (surface, subsurface), groundwater, building structures
Do not forget to characterize other hazards that may be present on the site after completion of the dismantling of the facility (conventional hazards, chemicals, bio-hazards).
Site characterization should be included in the characterization plan developed for decommissioning.
Take into account the history of the site and the operational history of the former facility.
Search for existing data / information, retrieve information from (former) staff.

26. Site Characterization
Perform sampling and measurements to identify radiological contaminants and concentrations.
Result of the characterization – 3D radionuclide distribution
Type and concentration of radionuclides
Homogeneity / heterogeneity
Contamination from leaks in tanks and pipes
Contamination below buildings
Other hidden and buried contaminated structures
Use of the results – to determine the need for and the extent of cleanup actions.
Do not mix the site characterization with the final survey.
Final survey has objective to demonstrate compliance with the release criteria after the completion of the cleanup actions.

27. Cleanup Actions Excavation of contaminated soil
Equipment / technology
Avoid any re-contamination !
Measurement to a predetermined gamma level (exclusion of natural radionuclides)
Clearance decision on excavated soil
Release of soil or management as radioactive waste
Identify a destination for the waste
Backfill of excavations with uncontaminated soil ?
Take, maintain and store samples and records of cleanup activities
Have cleanup levels been achieved?
Is unrestricted release possible? Iterative approach – “remove-measure”

28. Release of Materials from Nuclear Regulatory Control during the Cleanup Process
During cleanup of a site, radioactively contaminated material that is subject to regulatory control, with no intended future use, should be managed as radioactive waste at authorized RAW facilities in accordance with the characteristics of the material and its associated hazards.
Some contaminated material with a very low level of radioactivity may be suitable for release from regulatory control (clearance), for reuse in the nuclear industry or as a commodity in general industry (e.g. concrete, rubble), or for disposal in a disposal facility for non-radioactive waste.
Guidance exists on how to derive and apply clearance levels.
Criteria: the effective dose to any individual due to the cleared material is of the order of 10 μSv or less in a year
Unconditional clearance – values derived considering all pathways, multiple scenarios (Schedule I of the GSR Part 6)
Specific (conditional clearance) – higher values derived case by case for specific destination or reuse of the waste/material – some pathways and scenarios excluded, need approval by the RB
This topic was covered in the Workshop #9, Karlsruhe 2010

30. Release of Buildings
In general, a building can be released from regulatory control when all radioactive materials have been removed to the required level.
How to deal with inactive buildings (e.g. office building) on a licensed nuclear site?
A reasonable approach may target at giving evidence of clean buildings:
Provide evidence that radionuclides were never used
Provide evidence that contaminations did never occur
Provide factual evidence by random / designated measurement on the structures and by sampling

31. Release of Buildings
For contaminated buildings, which are planned to be reused or demolished, the following actions are typically carried out:
Decontaminate walls, ceilings, floors, as necessary;
Remove (deep) contaminated equipment and materials, also along fissures, cracks, joints etc.
Prevent re-contamination after decontamination! (Protect surfaces)
Clearance measurements on the existing structure
Clearance of the rubble of a demolished building is possible, but not the typical approach.

32. Final Survey Cleanup actions completed
Final survey plan approved as part of the decommissioning plan
Sampling equipment, instrumentation for measurements and laboratory equipment available
Procedures and trained personnel available
Radionuclides of concern known
Applicable site release levels known
Categorization of areas based on information on spills / contamination
Determination of boundaries of survey and survey units
Selection of background areas, if needed
Reference coordinate system

33. Final Survey Direct measurements and/or sampling
Determination of sampling locations
Sampling equipment
Sampling technique / Sample size
Analysis / Measurement
In case of contamination: increase density of grid / additional samples
Measurement Uncertainty
The radionuclide vector will inevitably differ slightly from the initial radionuclide vector
Monitoring techniques (e.g. emission probabilities in complex spectra, self-absorption, scan speed and detector size in case of field measurements)
Sampling variation
Analytical process imprecision
Background variability
Comparison to the derived site release criteria
Prepare a final survey report (part of the final decommissioning report)

34. Final Survey
Extensive information on the final survey will be provided in the other presentations during this workshop.
Detailed information is also available in the IAEA SRS 72 (2012).
In that publication the terms ‘remediation’ and ‘remedial cleanup’ are used for what is called ‘cleanup’ in this presentation and in the IAEA WS-G-5.1.

35. Unrestricted / Restricted Use after Release
After completing the cleanup activities, the operator should submit a final survey report to the RB, demonstrating that the site release criteria have been met.
The regulatory body should review the operator’s demonstration, confirm compliance with the criteria and release the site from regulatory control.
If the site complies with the appropriate release criteria when a reasonable set of potential future uses and associated uncertainties have been considered, the site should be released by the RB for unrestricted use, which is the preferred option.
The decommissioning phase should then be terminated and the RB does not need further involvement beyond keeping records about the site.
If after cleanup the site does not meet the release criteria, it can be considered for additional cleanup actions or for restricted use.
The release of sites for restricted use generally requires ongoing institutional involvement and control to implement the restrictions.
The type, extent and duration of the restrictions and controls needed should be proposed by the operator and approved by the RB.

36. Unrestricted / Restricted Use after Release
The restrictions should be proposed by the operator on the basis of a graded approach and in consideration of factors such as the type and level of residual contamination after the completion of cleanup, the relevant dose constraints and release criteria, and the human and financial resources needed to implement the restrictions and controls.
The restrictions should be designed and implemented to provide a reasonable assurance of compliance with the dose constraints. They should exclude or prevent exposure pathways leading to effective doses higher than the dose constraint (prohibit reuse for agricultural purposes, restrict access to the site).
The restrictions should be enforceable by the RB and it should be specified which organization will ensure that the restrictions are maintained.
There may be limits prescribed on the time frames for institutional control - these should be taken into consideration in deciding whether it is appropriate and reasonable to release a site for restricted use.
In addition, the way in which the restrictions would be removed in the future, when they are no longer necessary, should be specified.

37. Unrestricted / Restricted Use after Release
When the objectives of the site release have been accomplished to the satisfaction of the RB, the RB should formally notify the operator, other relevant competent authorities and interested parties of the decision to release the site from regulatory control.
In the event of a decision for restricted use, the notification should specify:
the restrictive measures to be applied;
their associated time frames;
the entities responsible for the implementation, monitoring and control of these restrictions.

38. Summary
Release of a site is the final step in decommissioning processes and aims at termination of the license for decommissioning. It is an authorized activity.
Release of sites typically involves the following steps:
Site characterization by the operator
Definition of the release criteria – prescribed by the RB or proposed by the operator and approved by the RB
Planning of the cleanup actions by the operator (review and approval by the RB)
Conduct of the cleanup actions by the operator (oversight by the RB)
Planning of the final survey by the operator (review and approval by the RB)

39. Summary
Conduct of the final survey by the operator (oversight by the RB)
Preparation of a final survey report by the operator to demonstrate compliance with the release criteria, submission to the RB
Review by the RB, independent confirmatory survey by the RB
Formal decision by the RB on unrestricted or restricted release
In case of restricted release, this decision includes
definition of restrictions
their duration
responsibilities for their implementation
An effective record management system for the released sites needs to be in place and to be maintained for future users of the sites.

40. Relevant IAEA Publications
Safety Requirements
Decommissioning of Facilities, IAEA Safety Standards Series No. GSR Part 6, IAEA, Vienna (2014).
Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards, IAEA Safety Standards Series No. GSR Part 3, IAEA, Vienna (2014).
Safety Guides
Decommissioning of Nuclear Power Plants, Research Reactors and Other Nuclear Fuel Cycle Facilities, Draft Safety Guide DS452, under preparation, revision of the WS-G-2.1 and WS-G-2.4
Application of the Concepts of Exclusion, Exemption and Clearance, IAEA Safety Standards Series No. RS-G-1.7, IAEA, Vienna (2004).
Release of Site from Regulatory Control Upon Termination of Practices, IAEA Safety Standards Series No. WS-G-5.1, IAEA, Vienna (2006).

41. Relevant IAEA Publications
Safety Reports
Standard Format and Content for Safety Related Decommissioning Documents, IAEA Safety Reports Series No. 45, IAEA, Vienna (2005).
Derivation of Activity Concentration Values for Exclusion, Exemption and Clearance, IAEA Safety Reports Series No. 44, IAEA, Vienna (2005).
Monitoring for Compliance with Exemption and Clearance Levels, IAEA Safety Reports Series No. 67, IAEA, Vienna (2012).
Monitoring for Compliance with Remediation Criteria for Sites, IAEA Safety Reports Series No. 72, IAEA, Vienna (2012).

42. Relevant IAEA Publications
Nuclear Energy Series and Technical Reports
Managing Low Radioactivity Material from the Decommissioning of Nuclear Facilities, IAEA Technical Reports Series No. 462, IAEA, Vienna (2008).
Determination and Use of Scaling Factors for Waste Characterisation in Nuclear Power Plants, IAEA Nuclear Energy Series No. NW-T-1.8, IAEA, Vienna (2009).
Long Term Preservation of Information for Decommissioning Projects, IAEA Technical Reports Series No. 467, IAEA, Vienna (2008).
An Overview of Stakeholder Involvement in Decommissioning, IAEA Nuclear Energy Series NW-T-2.5, IAEA, Vienna (2009).
E-versions available free of charge on the IAEA publications web pages:

43. THANK YOU FOR YOUR ATTENTION !

44. Supplementary Slides

45. Exposure Situations (GSR Part 3)
Planned exposure situation - exposure that arises from the planned operation of a source or from a planned activity that results in an exposure due to a source.
Exposure at some level can be expected to occur. If exposure is not expected to occur with certainty, but could result from an accident / event / sequence of events that may occur, this is referred to as ‘potential exposure’.
Emergency exposure situation - exposure that arises as a result of an accident, a malicious act or any other unexpected event, and requires prompt action in order to avoid or to reduce adverse consequences.
Existing exposure situation - exposure that already exists when a decision on the need for control needs to be taken.
Includes situations of exposure to natural background radiation, exposure due to residual radioactive material from past practices that were not subject to regulatory control or exposure that remains after an emergency exposure situation.

46. Exposure Situations (GSR Part 3)
Decommissioning is considered a planned exposure situation.
All the activities prior to termination of the authorization (licence) for decommissioning fall under the planned exposure situations.
Example of an existing exposure situation is a remediation of a contaminated land outside of a licensed site.
Dose constraints and reference levels are used for optimization of protection and safety.
Dose constraints are applied to occupational exposure and to public exposure in planned exposure situations.
Reference levels are used for optimization of protection and safety in emergency exposure situations and in existing exposure situations.

47. Concept of Exclusion
Exclusion - any exposure whose magnitude or likelihood is essentially not amenable to regulatory control and is deemed to be excluded from standards / legal framework
K40 in the human body
Cosmic radiation at the surface of the Earth and terrestrial radiation
Fallout from atmospheric weapons testing

48. Concept of Exemption
Exemption - Practices and sources within a practice may be, a priori, exempted from the requirements of standards (not from legal framework) if exposures or risks will be sufficiently small (trivial) or regulatory control of the practice or the source would yield no net benefit.
Based on the 10 Sv/y criteria (1 mSv/y for low probability scenarios)
Need to specify quantitative criteria – nuclide specific total activity or activity concentration, amounts of material
Tables I.1 (moderate amounts) and I.2 (bulk amounts) of the IAEA GSR Part 3
Justify practice (more overall benefit than detriment)

49. Concept of Clearance
Clearance - Removal of radioactive materials or objects from within authorised practices without any further control by the regulatory authority
Radiation risks arising from the cleared material are sufficiently low (order of 10 Sv/y criteria)
Continued regulatory control of the material would yield no net benefit
Trivial amounts of radionuclide / trivial exposures
Clearance levels shall not be higher than exemption levels
Clearance of bulk amounts of material may require particular regulatory consideration

50. Concepts - Summary
Excluded and exempt materials do not enter the nuclear regulatory regime. They remain outside of regulated practices.
Cleared materials are released from within the nuclear regulatory regime to outside of regulated practices.
The government or the regulatory body shall determine which practices or sources within practices are to be exempted from some or all of the requirements of these Standards.
The regulatory body shall approve which sources, including materials and objects, within notified practices or authorized practices may be cleared from regulatory control.

51. Regulatory Control of Radioactive Material
Authorized
Discharge
Exclusion
Authorized
Disposal
Radioactive
Material
Regulatory
Control
Clearance
Release of sites
Exemption